Disposition of comments for the Accessibility Guidelines Working Group

This success criterion delivers less in the user experience than UAAG 1.0, checkpoint 3.1. UAAG makes this subject to user profiling.

Single-switch users, for example, rely on context changes that are animated by the system, not triggered one by one by the user.

Low-vision users will come down on different sides of this question depending on how much of the content they can see at once and how much of the session structure they can hold in their head.

Proposed Change:

Best
Make equivalent facilitation (now 4.2) a principle. Include user configuration of the user experience under one of the forms of alternative recognized. State user experience requirements separately; define these by reference to UAAG 1.0. State data-on-the-wire requrements separately. These have two options:

turnkey format -- player meets UAAG requirements directly.
open format -- format populates machinable content model (c.f. rewritten 4.1) with information and actions that let UA manage and provide this capability.

2.3.2: This should be L2 or there should be a L2 equivalent

Proposed Change:

Create L2 equivalent

Images for markup: Seeing as this WCAG1 checkpoint does not map to a particular SC, does this mean that WCAG2 allows images to be used instead of markup, for example, images of text, instead of CSS-manipulated text? Or images for bullets instead of marked up bulleted lists?

Proposed Change:

Clarify the mapping of 3.1.

Properly positioned labels: 10.2 no longer maps to any particular SC. Although this checkpoint was included in WCAG1 to assist people who use screen readers, prior to the uptake of explicit labelling, this is still a very important SC for people who use magnifiers and people with cognitive disabilities.

Proposed Change:

Create a new SC the equivalent of 10.2 (I am happy to write this)

Definition of USER AGENT is "any software that retrieves and renders Web content for users". In several places it is emphasized that this includes assistive technology, but this definition seems to exclude many types of assistive technology such as speech recognition used for command-and-control, which neither retrieves nor renders, but does rely on access to the information being rendered. Also, the word "retrieves" seems to imply fetching from some remote source (e.g. over the Web), which would exclude screen readers; on the other hand, "retrieves" could be taken to mean getting the data from anywhere, including from another user agent, but by that interpretation a display driver would count as assistive technology.

Proposed Change:

Change to read "any software that retrieves and renders Web content for users, or manipulates such content to assist the user in using the Web content or controls"

4.1.2: What is the "name" or the "role"? What does it mean "values can be set by the user"?

Proposed Change:

Rewrite SC 4.1.2

Definition of accessibility - In the Baseline document (under the heading 'If the WCAG does not set the baseline, then how can we be sure that a site will be accessible?) it says "No site or content is ever completely accessible". In the Conformance document it says "Note that even conformance to all three levels will not make web content accessible to all people." I strongly object to these statements. All content can be made accessible. In some cases, content may not be accessible, but if the problems were identified it could be made accessible. As the main body representing accessibility I think it reprehensible that we have these statements.

Proposed Change:

Remove the statements. Merge Level 1 and Level 2 SC into one group called 'Mandatory'. Rename Level 3 to 'Advisory' or 'Optional'

2.4.7: This should be at Level 1. Determining the current location is sometimes very difficult for both people who use screen readers and people with cognitive disabilities

Proposed Change:

Move to Level 1

2.5.4: This should be Level 1. Context sensitive help is very important to people who use screen readers and people with cognitive disabilities.

Proposed Change:

Move to Level 1

3.1.4: If information is provided in an abbreviated form without expansion, then the content is essentially inaccessible to people that cannot interpret the abbreviation. People who use screen readers and people with cognitive disabilities often have difficulties interpreting abbreviations.

Proposed Change:

There should be a Level 1 version of this SC which requires that important abbreviated information is marked up, or expanded the first time it is used in a page

3.2.1 & 2.2.5: From my reading, 3.2.1 outlaws changes of context when a component receives focus, but 2.2 allows changes in content for no reason (only outlawing at L3)

Proposed Change:

Rewrite SC 3.2.1 and 2.2.5

4.1: There should be (preferably at Level 1) a requirement for content to validate

Proposed Change:

Create a Level 1 SC requiring validation

2.2.6: This should be at Level 2. If someone is using an authenticated session and cannot complete the information before automatic logoff, then being able to continue after re-login is imperative in order to use the system. Otherwise the system is inaccessible

Proposed Change:

Move 2.2.6 to Level 1

Navigation is a User Agent function enabled by structure in the content. This is not a content guideline, but a user experience requirement handled in the User Agent.

Proposed Change:

Replace with a narrower provision that says "navigation paths defined in the content encoding correspond to the logical order information which is the subject of 1.3.3"

Term: Programmatically determined - The definition for "programmatically determined" is "determined by software from data provided in a user-agent supported manner such that the user agents can extract and present this information to users in different modalities". What is the definition by "user agent supported manner"? Does this mean that even if only one user agent on only on version of an operating system can extract the information then it complies? What about people with colour blindness? If faced with an image they can't interpret due to colour blindness, they could just use a colour picker tool which will tell them the hex values of each pixel and determine the contents of an image that way.

Proposed Change:

Redefine SC that use the term programmatically determined

Stylesheets: It could be argued that the sequence of content can always be programmatically determined- otherwise it could not be presented to the user in that particular sequence. Because 1.3.3 maps to checkpoint 6.1, it is obvious that what is meant by the WCAG2 SC is that if style sheets are used to manipulate the layout of text, then the layout without style sheets must present a meaningful alternative. However it can be argued that simply because a user agent (ie browser) can interpret the style sheet to present information in a certain way, that it is automatically programmatically determinable.

Proposed Change:

Clarify the SC 1.3.3

Baseline CSS: This mapping essentially says that if CSS is in the baseline then information can be put into the style sheet and not in the HTML. This appears to allow formatting (ie headings) via CSS and not HTML, important images included in CSS and not HTML, etc. How is someone who uses a screen reader going to interpret this? How are they going to be able to access the information they require?

Proposed Change:

Clarify baseline requirements

1.4.2 requires a mechanism to turn off "background audio that plays automatically, without requiring the user to turn off all audio". This is good except that "background audio" is not defined. Is it audio that is played at the same time as other audio, but is considered to be less important (i.e. background behind other audio)? Or Is it audio that is purely decorative and/or atmospheric, but not required for understanding or use of the web unit (regardless of whether other audio is playing)?

Proposed Change:

Define "background audio", or change "background audio" to either "audio" or "purely decorative audio".

2.2.3. requires that content can be paused by the user (barring certain exceptions). Pausing, as opposed to Stopping, implies there is UI to un-pause the content. Would it be acceptable to allow decorative content to be stopped, but not provide UI to resume it? The current wording would preclude that.

4.1.1 requires that Web content to be parsed unambiguously. Does this require the formal specifications be open, so that new user agents can parse the content? For example, suppose the baseline specifies just one Web browser, that implements rules for applying defaults to resolve any potential ambiguities in HTML that might be interpreted differently if another browser were used; is the HTML parsable unambiguously within the scope of the baseline? As another example, suppose a Web uses a proprietary data format that only a single plug-in can render; does it matter if it's parsable unambiguously if there is only one renderer?

Proposed Change:

Insert the phrase ", using publicly available specifications", to read "Web units or authored components can be parsed unambiguously, using publicly available specifications, and the relationships in the resulting data structure are also unambiguous.